ID: aiam2012

Dear Mr. Huneke: #Please forgive the delay in responding to your lette of March 24, 1975, to Mr. Schwimmer of this office concerning the application of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*, to new brake hose assemblies whose end fittings are partially disassembled by vehicle manufacturers. #You have described brake hose assemblies equipped with permanent end fittings containing sacrificial sleeves. Although the assemblies are complete when delivered by you to a vehicle manufacturer, they must be partially disassembled by him (because they lack swivel fittings) to facilitate installation in vehicles. At this point the vehicle manufacturer does not, as you have suggested, become the hose assembler, assuming responsibility for the assemblies' compliance with the standard and relieving you of responsibility for their continued compliance. He is not, however, required to remove the assembler's band which you have installed pursuant to S5.2..4 (as incorporated by reference in S7.2 and S9.1), although he is free to do so, nor is he required to install his own band, because of the exception in S5.2.2 for assemblies which are assembled and installed by a vehicle manufacturer in his own vehicles. Furthermore, he is not required to replace the sacrificial sleeve in the end fittings, because that sleeve has not been used. #An aftermarket purchaser who disassembles and then reassembles one of your assemblies also relieves you of responsibility for its continued compliance with the standard. He is not required to remove your assembler's band, nor is he required to replace the sacrificial sleeve. #Sincerely, Frank Berndt, Acting Chief Counsel;

ID: GF004197

Mr. Robert Babcock
Manager, Corporate Affairs
Hyundai America Technical Center, Inc.
5075 Venture Drive
Ann Arbor, MI 48108




Dear Mr. Babcock:

This responds to your letter regarding applicability of Federal Motor Vehicle Safety Standard (FMVSS) No. 201, Occupant Protection in Interior Impact, to items attached to a floor-mounted console. You specifically ask about a foldable video monitor that is attached to the console. Our answer is the monitor you depict would be excluded.

FMVSS No. 201 establishes performance requirements designed to reduce the risk of injury in the event an occupant strikes the interior of a vehicle during a crash. Specifically, certain areas within the vehicle must be properly padded or otherwise have energy absorbing properties to minimize head injury in the event of a crash. Head impact protection performance is determined, in part, by testing specific targets on the vehicle interior.

S5.1.1(a) of FMVSS No. 201 excludes console assemblies from the head impact protection requirements of the standard. Although console assemblies are not defined in FMVSS No. 201, they commonly refer to low-lying structures mounted on the vehicle floor between the front seats. You ask if the exclusion in S5.1.1(a) would apply to a foldable video monitor attached to the console.

The height of a console assembly is not limited by our standards. If the monitor were permanently incorporated into the console in the protruded position, it would be considered part of the console and excluded from the standard even though the height of the console would be unusually high. The fact that the monitor you are considering can fold to a "stored" position does not have a bearing on whether the monitor is part of the console. We consider a video monitor attached to the console to be part of the console even when it is foldable.

If you need further assistance, please contact George Feygin of my staff at this address or at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:201
d.7/7/05

ID: aiam0025

Dear Mr. Combe: In answer to your letter of May 26, concerning Federal Motor Vehicl Safety Standards Nos. 208 and 210, your interpretation is correct: a four-passenger automobile (such as the Peugeot 404) must have two Type 2 seat belt assemblies for the front seat passengers if the windshield header is within the head impact area, two Type 1 or Type 2 seat belt assemblies for the front seat passengers if the windshield header is not within the head impact area, and two Type 1 seat belt assemblies for the rear seat passengers. However anchorages for Type 2 seat belt assemblies are required in the rear to enable the owner to install Type 2 seat belt assemblies should he desire to afford his rear seat passengers this means of protection.; Sincerely yours, Robert M. O'Mahoney, Assistant General Counsel

ID: aiam0026

Dear Mr. Combe: In answer to your letter of May 26, concerning Federal Motor Vehicl Safety Standards Nos. 208 and 210, your interpretation is correct: a four-passenger automobile (such as the Peugeot 404) must have two Type 2 seat belt assemblies for the front seat passengers if the windshield header is within the head impact area, two Type 1 or Type 2 seat belt assemblies for the front seat passengers if the windshield header is not within the head impact area, and two Type 1 seat belt assemblies for the rear seat passengers. However anchorages for Type 2 seat belt assemblies are required in the rear to enable the owner to install Type 2 seat belt assemblies should he desire to afford his rear seat passengers this means of protection.; Sincerely yours, Robert M. O Mahoney, Assistant General Counsel

ID: nht88-1.5

TYPE: INTERPRETATION-NHTSA

DATE: 01/01/88 EST

FROM: JERRY'S SERVICE

TO: LEGAL OFFICE NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 08/19/88 TO DOUGLAS H BOSCO, FROM ERIKA Z JONES, REDBOOK A32 (2) STANDARD 108; LETTER DATED 06/16/88, TO ERIKA Z. JONES, FROM DOUGLAS H. BOSCO; LETTER DATED 08/03/87 TO DOUGLAS H. BOSCO FROM ERIKA Z. JONES; LETTER DATED 06/09/88 TO JERRY K YOST FROM L. F ROLLIN; LETTER DATED 03/28/88 TO C-MORE-LITE JERRYS SERVICE FROM DON O. HORNING RE TEST REPORT NO 92606;

TEXT: NAME OF UNIT

C-More Light Headlight Relay.

DESCRIPTION OF UNIT

The unit is a replacement headlight relay. See technical drawings A-1, A-2, A-3, and A-4.

The C-More Light Headlight Relay allows the driver to select either high or low beam headlights, as is presently the case. The difference with this relay is that as the driver chooses to add more light by changing from low to high beams, the highbeam is added to the low beam; rather than turning the low beam off and the highbeam on. The choice is no longer either low or high; it is low beam always, with or without highbeam added.

BENEFITS OF THE UNIT

It can be added to virtually every motor vehicle as an after market device.

It can easily replace all headlight relays now being used during manufacture of motor vehicles.

It increases motoring safety by adding more light to the roadway. See diagrams B-1, B-2, and B-3. 2000 candle power is added during highbeam operation.

It increases motoring safety by continuing to light the dark area immediately in front of the motor vehicle now being created as low beams are turned off and highbeams are turned on. This area is overshot by highbeams.

It increases motoring safety by continuing to provide low beam illumination if high beam is defective. Currently, if one high beam is burned out and high beams are selected by the driver, there is no light from that side of the vehicle. This unit allow s the low beam to continue to provide light.

It increases motoring safety by eliminating the delay between low and highbeam operation. In properly functioning systems this delay is minescule and is hardly noticed by the average driver. However, as vehicles become older this delay often becomes lo nger and may be critical at highway speeds. The delay is eliminated by the continuous operation of the lowbeams.

PERFORMANCE TESTING OF THE UNIT

The units have been in limited use since 1965.

Drivers of the equipped vehicles report greater awareness during hours of darkness. Use of the unit does not seem to affect oncoming drivers as the added light is between the front of the vehicle and the area covered by the highbeams, and the lights are required to be dimmed in any case.

The C-More unit has not adversely affected the balance of the motor vehicle electrical system. If an electrical short occurs, the dimming system continues to operate in the old, "either/or" mode.

There appears to be greater low beam life; most likely due to a lessening of the number of on/off changes.

ID: nht89-3.31

TYPE: INTERPRETATION-NHTSA

DATE: 11/06/89

FROM: STEPHEN P. WOOD -- NHTSA ACTING CHIEF COUNSEL

TO: WOLFRED FREEMAN -- FREEMAN & COMPANY

TITLE: NONE

ATTACHMT: LETTER DATED 06/22/89 FROM WOLFRED FREEMAN TO NHTSA

TEXT: Dear Mr. Freeman:

This is in reply to your letter to June 22, 1989, to the Administrator-Designate, General Curry, in which you "petition . . . for permission to produce a color coded (Green-Amber-Red) rear light device for all types of motor vehicles." You have designed "a workable auxiliary system that can be adopted to cars and trucks on the road."

We are treating your letter as a request for an interpretation of whether your device would be permissible for sale and use as an item of aftermarket equipment under the regulations and statutes administered by this agency. By aftermarket, we mean sale of the device for installation on cars and trucks in use, as contrasted with sales by dealers for installation on new cars. The principal regulation of this agency pertaining to motor vehicle lighting equipment is Federal Motor Vehicle Safety Standard N o. 108. The only requirements it establishes for the aftermarket is for equipment that is intended to replace the original lighting equipment specified by the standard (for example, headlamps and stop lamps). As your device is not a required item of mo tor vehicle lighting equipment, there is no Federal standard that applies to it.

However, the National Traffic and Motor Vehicle Safety Act has a direct relationship to the acceptability of aftermarket equipment. The Act prohibits modifications by persons other than the owner of the vehicle if they render inoperative, in whole or in part, equipment that is installed pursuant to a safety standard. Under Standard No. 108, this equipment includes stop lamps, turn signal lamps, hazard warning signals, turn signals, backup lamps, taillamps, and the license plate lamp. On large trucks, it also includes identification lamps and clearance lamps. If the potential effect of an auxiliary lighting device is to create confusion as to the intended message of any lighting device required by Standard No. 108, we regard the auxiliary light as h aving rendered the required lamp partially inoperative within the prohibition of the Act.

Thus, the question is whether your device has the potential to create confusion so that its installation by a manufacturer, distributor,

dealer, or motor vehicle repair business would be a violation of the Act. We do not conclude that the device has this potential. In your device, a steady-burning amber light would signal that the accelerator had been released (and that neither the acce lerator nor brake pedal were being applied). Amber is the recognized signal for caution. This signal will extinguish when either the accelerator (green signal) or brake pedal (red signal) is applied. Furthermore, it is steady burning whereas other rear lamps where amber is an optional color (turn signals and hazard warning signals) flash in operation. Therefore, it does not appear that your device would create confusion with required items of lighting equipment.

You must also consider whether the device would be acceptable under the laws of any State where it is sold and used. We are unable to advise you on State laws, and recommend that you contact the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203. However, we believe that in several Western States, there has been specific legislation that would permit your device.

We appreciate your interest in enhancing vehicle safety through improvement in rear lighting systems. We believe that improvements, such as the center highmounted stop lamp, should be introduced as standardized, mandatory lighting equipment on vehicles, rather than as optional aftermarket devices. Contrary to your understanding, our studies of a system similar to yours showed no discernible improvement in reaction time or accident avoidance over current systems.

Sincerely,

ID: aiam0286

Dear Mr. Dietrich: This is in reply to your letters, both dated December 16, 1970 concerning Motor Vehicle Safety Standard No. 213, Child Seating Systems.' One of these letters enclosed a request for clarification of two provisions of Standard No. 213. This request is presently under review and you should be hearing from the agency concerning it in the near future. You also enclosed in this letter a copy of a page from the 1970 Sears, Roebuck & Co. catalogue showing a child harness that is advertised as not a safety harness,' and ask whether this type of harness is exempt from the requirements of Motor Vehicle Safety Standard No. 209. The agency considers these types of harnesses to fall within the purview of Standard No. 209 and they are required to comply with the requirements for Type 3 seat belt assemblies as specified in S4. of that standard. Enforcement procedures are currently in progress in this area to eliminate those child harnesses that do not comply with the standard.; Your second letter requests that a study conducted by the University o Michigan Highway Safety Research Institute (Contract No. FH- 11-6962), entitled Integrated Seat - Restraint and Child Systems,' be placed in the public docket, and further request that the data films of the dynamic sled test be made available through the Docket.' The report to which you apparently refer has been placed in the general reference section of Docket 2-15. It is entitled Child Seat and Restraint Systems Test Program' but bears the same contact number as the one you request. With reference to your request for data films, these films are presently available for examination by the public through the agency's Research Institute, and information to this effect has been placed in the Docket.; We are pleased to be of assistance. Sincerely, Lawrence R. Schneider, Acting Chief Counsel

ID: aiam0285

Dear Mr. Dietrich: This is in reply to your letters, both dated December 16, 1970 concerning Motor Vehicle Safety Standard No. 213, 'Child Seating Systems.' One of these letters enclosed a request for clarification of two provisions of Standard No. 213. This request is presently under review and you should be hearing from the agency concerning it in the near future. You also enclosed in this letter a copy of a page from the 1970 Sears, Roebuck & Co. catalogue showing a child harness that is advertised as 'not a safety harness,' and ask whether this type of harness is exempt from the requirements of Motor Vehicle Safety Standard No. 209. The agency considers these types of harnesses to fall within the purview of Standard No. 209 and they are required to comply with the requirements for Type 3 seat belt assemblies as specified in S4. of that standard. Enforcement procedures are currently in progress in this area to eliminate those child harnesses that do not comply with the standard.; Your second letter requests that a study conducted by the University o Michigan Highway Safety Research Institute (Contract No. FH- 11-6962), entitled 'Integrated Seat - Restraint and Child Systems,' be placed in the public docket, and further request that the 'data films of the dynamic sled test be made available through the Docket.' The report to which you apparently refer has been placed in the general reference section of Docket 2-15. It is entitled 'Child Seat and Restraint Systems Test Program' but bears the same contract number as the one you request. With reference to your request for data films, these films are presently available for examination by the public through the agency's Research Institute, and information to this effect has been placed in the Docket.; We are pleased to be of assistance. Sincerely, Lawrence R. Schneider, Acting Chief Counsel

ID: nht94-1.35

TYPE: Interpretation-NHTSA

DATE: January 31, 1994

FROM: Steve Williams -- Director, Public Transportation, Mississippi Department of Education

TO: William Moss -- Superintendent, Jones County School District

TITLE: None

ATTACHMT: Attached to letter dated 5/31/94 from John Womack to Mike Parker (A42; Std. 222; Part 571.3), letter dated 4/18/94 from Mike Parker to Christopher Hart, and letter dated 1/28/94 from Steve Williams to Terry L. Voy

TEXT:

On January 24, 1994, Jon Harper and I met with James Green, Transportation Director, and George Dukes, Chapter I Coordinator from your district, to discuss the installation of VCR's and TV monitors on school buses. Pursuant to our visit, I have contacte d school bus engineers which advise against such installation due to liability concerns. In addition, I am requesting an interpretation and opinion from the National Standards for School Buses and Operations Interpretation Committee to determine if the national school bus standards prohibit such installation (copy attached). The interpretation will clarify this matter because Mississippi bus standards are modeled after and based upon the national standards. My discussion with a representative from tha t committee indicated that without official testing and standardization procedures, such installation would probably not be advisable.

Until such time that we can receive the opinion based on the National Standards for School Buses and Operations, we cannot support and would advise against installation of VCR's and TV monitors. It is my understanding that a school district in Arizona h as installed such equipment. Nonetheless, it is incumbent upon our office to ensure that there is no violation of safety standards regarding the school buses that transport students to and from school or related activities.

We will advise you of the Interpretation Committee's opinion as we receive it. If you have any questions, please let me know.

ID: aiam5276

"Dear Mr. Chung: This responds to your letter of November 3, 1993, t Mr. Vinson of this Office, with respect to calculation of the application of conspicuity treatment to container chassis trailers. The length of the gooseneck is included in determining the overall length of the trailer for purposes of calculating the half length that must be covered by the conspicuity treatment (which, of course, would be greater than half the length behind the gooseneck). For example, let us say that the overall length of the trailer is 40 feet, including an 8-foot gooseneck. The amount of the side to be covered is not less than 20 feet. The area to be covered is the 32 feet between the rear bolster to the point immediately behind the gooseneck's terminus. Thus, at least 20 feet of this 32-foot length must be covered in order to comply with Standard No. 108. There is nothing in Standard No. 108 that precludes the application of retroreflective sheeting to the gooseneck. Indeed, some manufacturers may wish to do so to provide conspicuity of the trailer side when the trailer is traveling without its cargo. However, any conspicuity treatment on a gooseneck is not counted in determining whether at least half the trailer side is covered. I hope that this clarifies the matter for you. Sincerely, John Womack Acting Chief Counsel ";